PRIVACY POLICY
We are committed to ensuring that your privacy is protected. This Privacy Policy lets you know what information we may collect from you, how we collect it, how we use it and with whom we share it.
This Privacy Policy applies to your use of (1) the websites located at www.nathanarrow.com, www.nathanarrow.co.uk and www.nathanarrow.net (the 'Website') and the iOS application (the ‘App’) which are operated by Nathan Arrow Limited ('Nathan Arrow' or 'us' “our” or 'we’), and (2) any of our products or services (including support services) which may be accessible via the Website, App, third party platform or otherwise. We will call them together our “Services.”
This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
By using any of our Services, you confirm that you have read, understood and agree to all of the terms of this Privacy Policy. If you have any questions, please email Christine Williams at christine@nathanarrow.com, who is our Data Protection Officer.
We are a registered data controller of personal data under the Data Protection Act 1998, registration number Z3235236.
We may change this Privacy Policy at any time. Any amendments to this Privacy Policy will come into effect a reasonable period of time. As a guide, normally we consider 30 days to be a reasonable time period, so you should check this page from time to time to ensure that you are happy with any changes.
This Privacy Policy forms part of our Terms and Conditions, which are available upon request.
TYPES OF PERSONAL INFORMATION THAT MAY BE COLLECTED
The information we collect about you can include information which, on its own or together with other information, can be used to identify you as an individual (“Personal Information”). We also collect other information which does not personally identify you. All of this can include:
(i) Information That You Provide Us:
When you visit certain sections of the Services, we may ask you to provide us with specific information, including (but not limited to):
• contact information, such as your name, mailing address, phone number and email address
• unique identifiers such as a user name and password
• financial information, such as your debit/credit number or similar information (we do not share credit card details with any 3rd parties)
• any other information which you supply to us.
(ii) Services Usage Information:
We may receive and store certain types of Internet usage information whenever you use the Services such as:
• your IP address; your Media Access Control (MAC); any device Unique Device Identifier (UDID) or equivalent; your operating system, browser type or other software; your hardware or mobile device details (including your mobile device type and number and mobile carrier details), if applicable; or other technical details. This is technical data about our users and their actions and patterns, which we do not believe identifies any individual to any third parties.
• your landing page; order of pages viewed; metrics information about when and how you use the Services; traffic data; potentially certain information from third party services, strictly in accordance with the applicable networks' terms and conditions (and with your prior consent); and your geographical location data
• other personal or business information you give us in order to help you with any queries or support matters via Services.
HOW INFORMATION IS COLLECTED
(i) Registration: when you register for the Services, you must complete a registration form and provide personally identifiable information. You may also be asked to choose a password.
(ii) Support: information given when you contact us or report a problem with the Services.
(iii) Cookies: as with many websites, our Websites uses a technology called 'cookies'. Cookies automatically identify your browser to the Website whenever your computer is used the visit the Website. Accepting cookies enables you, among other things, to personalise your experience on the Website. If you do not want information collected through the use of cookies, your browser should contain an option that allows you to disable or delete cookie data at any time. Some areas of the Website, however, may not provide you with a personalised experience if you have disabled the use of cookies. The cookies are not tied to Personal Information.
(iv) Transaction Information: If you conduct a financial transaction on the Services, you may be required to provide certain financial information, including contact information and debit or credit card details. We will use this information to complete the transaction that you have requested. [We do not store any of your payment card details.] This information is encrypted, securely stored and processed by HSBC (as may be updated from time to time) so that we can bill you in accordance with your initial fee.
(v) Third Parties/Public sources: we may collect information from third parties or from public sources. This information may be used in various ways such as to verify your identity and to carry out AML checks.
HOW WE USE THE INFORMATION COLLECTED
As applicable, the information you provide may be used to (this list is not exhaustive):
• Contact you about the Services and relevant updates to these
• Carry out our obligations arising from any contracts between you and us
• Contact you relating to your subscription or user status
• Confirm or fulfil an order you have made
• Send you print or electronic publications about Nathan Arrow
• Monitor and track your use of our products and services
• Monitor your compliance with the Terms and Conditions
• we may use your credit card details to process payments due to us in accordance with the Terms and Conditions
• Maintain website security
• Notify you about changes to our Services
• To ensure that content from our Services is presented in the most effective manner for you and for your computer or other device from which you access services and enhance navigation
• Provide you with information, products or services that you request from us
• Unless you have opted out of receiving direct marketing from us in this way, provide you with information, products or services that we offer and which we feel may interest you
• Unless you have opted out of receiving direct marketing from us in this way, offer you information, products or services from carefully selected third parties.
WITH WHOM THE INFORMATION MAY BE SHARED
We may share your Personal Information with third party partners, suppliers and sub-contractors who work with us to provide the Services to you in order to support, improve or amend any Services. We may also share your non-Personal Information with data analysis services.
We may share your Personal Information with selected third parties in order to enable us to provide you with information about that third party’s goods and services which we consider may be of interest to you.
We may employ the services of third parties to assist us in certain areas of our business i.e. website hosting, sending marketing emails etc. It may be the case that we have to disclose Personal Information to those third parties in order to enable them to provide those services to us. We will at all times retain control of your Personal Information and those third parties may only use your Personal Information for the purposes of providing those services to us.
We will not share your information with third party advertisers except with your consent. We do not disclose Personal Information about identifiable individuals to advertisers, but we may provide them with aggregate and/or anonymised information about our users to help advertisers reach the kind of audience they want to target. We may make use of the information we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
AMENDING OR UPDATING YOUR PERSONAL INFORMATION
If you are a European Union citizen, you have the right to ask us not to use your Personal Information for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at christine@nathanarrow.com. EU data protection legislation gives EU citizens the right to access information held about you. You may at any time request details of Personal Information which we hold about you, which we will supply on verification of your identity and payment of the standard £10 charge under the Data Protection Act 1998. If you believe that any information we are holding on you is incorrect or incomplete, you can change this in your user account. Alternatively, you may email us and we will promptly correct any information found to be incorrect within 30 days.
BUSINESS TRANSFERS
We may disclose your information (including Personal Information) to third parties if we sell or buy appropriate business or assets, in which case we may disclose your Personal Information to the prospective or actual seller or buyer of such business or assets. If we or substantially all of our assets are merged with or acquired by a third party, Personal Information held by us about our customers will be one of the transferred assets. We may share or disclose your information (including Personal Information) with third parties if we are under a legal duty to do so, or in order to enforce or apply any terms and conditions applying to any of the Services; or to protect our rights, property, or the safety of our customers or others.
SECURITY
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
The information that we collect from you may be transferred to, stored and processed at a destination outside the European Economic Area (“EEA”) (including the USA). It may also be processed by staff operating outside the EEA. By submitting your Personal Information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.
All private information is protected by a dedicated SSL certificate. We also perform daily offsite backups, and your data is available for export at any time.
The server is housed with 1&1 Internet. The data centres are located within secure compounds; entry to the buildings is via unique access codes and covered by 24-hour on-site security and motion detection CCTV. Unfortunately though, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our servers via any of our Services; any transmission is at your own risk.
LINKS TO OTHER WEBSITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Statement. You should exercise caution and look at the privacy statement applicable to the website in question.
OUR STATUS IN EU DATA PROTECTION LAW
In relation to our provision and administration of the Services, we are the data controller under the United Kingdom's Data Protection Act 1998. In other circumstances we may be a data processor. We respect your right to privacy and will only process Personal Information you provide to us in accordance with the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other applicable privacy laws.
CONTACT US
We welcome any questions, comments and requests regarding this Privacy Policy, which should be addressed to christine@nathanarrow.com